Privacy Policy
Last updated: February 29, 2020
1. General Provisions

1.1. This personal data processing policy is used by Individual Entrepreneur Eugeny Viktorovich Dementiev (OGRNIP 317470400082431) (hereinafter referred to as the "Operator"), the administrator/owner of the Harmony mobile application for iOS and Android (hereinafter referred to as the "Application") processing personal data of personal data owners who freely, voluntarily and in their interest provide their personal data when registering in the Application (hereinafter referred to as the "Users").

1.2. User' registration in the Application means that the User unconditionally accepts this Policy and the conditions of personal data processing the Policy specifies. In case of disagreement with the conditions of the Policy the use of the Application and its services must be immediately terminated.

1.3. Consent to personal data processing can be given in electronic form using the consent to personal data processing hosted in the Application.

1.4. The Operator is entitled to make changes and additions to this Policy in case of adoption of new laws and regulations pertaining to personal data protection. In case of any changes in the Policy the Operator shall put its new version in the Application so that it is freely accessible by the Users.

2. Volume and Content of the Users' Personal Data

2.1. To be registered the User shall independently provide the following personal data:

  • name
  • date of birth
  • phone number

The Operator can also process technical data that are automatically transmitted by the device using the Application:

Data about the User's device (including resolution, version, and other attributes that characterize the User's device)

2.2. The Operator neither verifies the accuracy of the User's personal data, nor controls their legal capacity. The Operator assumes that the User's personal data are reliable. The User keeps this information updated.

2.3. The purposes of the User's personal data processing:

  • Rendering of services by the Operator
  • Communication with the User
  • Organization of participation in events and surveys conducted by the Operator
  • Sending of the Operator's news
  • Other purposes with the consent of the User.

3. Conditions of Personal Data Processing and Their Transfer to Third Parties

3.1. The User's personal data shall be kept confidential, unless the User voluntarily provides personal information for public access.

3.2. The User's personal data shall be processed using the automated systems unless non-automated personal data processing is necessary to comply with the legal requirements.

3.3. The Operator has the right to transfer the User's personal data to third parties only with the User's consent, and in cases provided for by the law.

3.4. The Operator has the right to entrust the User's personal data processing to third parties with the User's consent unless otherwise required by the law.

3.5. Processing of the User's personal data shall be carried out during the entire period of the User's registration in the Application.

4. Measures to Protect Personal Data

4.1. The Operator shall take necessary and sufficient legal, organizational and technical measures to protect the User's personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution, and from other illegal actions.

4.2. The Operator shall independently determine the composition and list of measures necessary to ensure the personal data protection.

5. Users' Rights

5.1. The Users have the right to receive information related to the processing of their personal data by sending to the Operator an appropriate request to the address:

5.3. The Operator shall send a response to the User to the address specified in the User's request within 30 days from the date of its receipt.

5.4. The Users can change (update, clarify) their personal data at any time by sending an appropriate request to the Operator's email address.

5.5. The Users can delete their personal data by sending an appropriate request to the Operator's email address.